Information for Study Center Directors and Staff

UC faculty and staff have access to student information only for legitimate use in the completion of UC responsibilities. As faculty and staff members performing a function on behalf of UC, SC Directors and staff have a legal responsibility under FERPA (Family Educational Rights and Privacy Act) and the California Information Practices Act (IPA) to protect the confidentiality of student educational records in their possession.

UC policies applying to the disclosure of information from student records are contained in the UC Policies Applying to Campus Activities, Organizations, and Students, a UC systemwide document from the Office of the President. EAP’s Student Information Release Matrix will help SC Directors answer requests for disclosure of information from a student’s record. In compliance with US federal and California state laws, students may choose to exercise their right to restrict disclosure of any or all of their personally identifiable information (directory information and confidential information) when they apply to EAP. Students who choose to restrict disclosure of information will be flagged with a confidentiality icon in MyEAP. The confidentiality icon can be easily viewed next to the student’s full name in a Quick List mode. This confidentiality mark restricts disclosure of any information to third parties, including parents. Although UC encourages students to give UC officials consent to release information to parents, the only exception that allows UC faculty or staff to share information with parents is in the case of a safety or health emergency. UC treats all students as adults whether they are financially dependent or not, and UC treats parents like any member of the public in terms of what information UC officials can share with them. There are two types of educational records (personally identifiable information) as defined under FERPA: directory information and confidential information. Each type of educational record is afforded different disclosure protections.

UC may release certain information (directory information) about students without their permission. These items are listed in the Student Information Release Matrix. Students who have requested a higher confidentiality level are exercising their right to privacy. Technically, EAP cannot admit they are in the Program. There are few exceptions to this rule: disclosure to UC and/or host institution staff and faculty when such information is relevant and necessary in the performance of their UC duties, disclosure during a health or safety emergency, disclosure when the student specifically authorizes release of information, disclosure to officials in the UC Office of the President or the UC Office of the General Counsel, or disclosure to comply with a subpoena.

The Study Center may disclose directory (public) and non-directory (confidential) information about a student who has blocked the release of information only after the student gives specific authorization in writing to do so. If a parent requests information or wants to discuss a student’s personal situation, the SC Director should explain that the release of personally identifiable information (directory and confidential information) has been blocked and that an exception cannot be made, even for parents, without a student’s written authorization. Parents may generally be sympathetic if they understand that obtaining written consent from the student is a formality to comply with FERPA and other privacy laws. In the written authorization, the student should indicate specifically what kind of information may be released, to whom, and for what purpose. The letter must be dated and signed and can be submitted by fax, mail, or as a scanned e-mail attachment. The Study Center should keep a copy of such a statement and send UOEAP the original.

Students who have blocked the release of information may not be included on address lists circulated by the Study Center unless such students specifically grant permission.

When students apply for EAP and restrict the release of any or all of the categories of their personally identifiable information, it is possible that they may not fully understand the implications of their choice. Students may rescind their original instructions using the Authorization to Release Items of Public Information form. The original copy of this form should be forwarded to UOEAP as part of the student’s permanent record. Note that this authorization does not allow the disclosure of confidential (non-directory) information to third parties. The only information that can be released would be w

600.01 Communications, Confidential

The SC Director may feel it necessary to write an “in confidence” letter to UOEAP on a matter relating to a student’s health that is intended as background information for UOEAP’s Operations or Academic Specialists and/or a physician, psychiatrist, or psychologist advising the SC Director or student concerning a specific problem. If such a letter is marked “in confidence,” it will be stapled closed when filed and/or shared with a professional or paraprofessional acting in his or her capacity to assist the student. Copies of e-mail or faxes and telephone call notes will be handled on the same basis. All materials, whether they are placed in the student’s file or not, are legally part of the file, even when stored elsewhere. The student’s file is subject to the student’s review at his or her request in accordance with California and federal laws. However, the laws do not mandate that records be made or kept in every instance, so the SC Director may wish to exercise judgment in this regard. Legally, records may be discarded at any time up to the student’s request to review his or her file. From the moment of the request, nothing may be discarded and all materials must be gathered for the student to review, regardless of where they have been stored.

600.02 Requests for Disclosure of Information from Student Records

There have been rare cases in the past when a host government authority has requested the SC Director to release information other than directory (public) information concerning a student (see Student Information Release Matrix).

If a request comes to the SC Director to release confidential information, he or she should immediately notify the student and explain the processes, as noted below, which will be followed in responding to the request.

The key question for the SC Director to address with these officials should be the degree to which the UC procedures, as outlined, are in conflict with the policies, regulations, and/or laws of the host institution and host country, and whether any relevant protocols exist between the US and the host government (and possibly a third country if the student is a foreign national).

On the basis of the procedures and consultations mentioned above, the SC Director should contact the appropriate Regional Director at UOEAP to:

The SC Director should notify the student immediately by means of the Disclosure of Student Records form as to whether or not his or her records were disclosed. The SC Director should send a copy of this form to UOEAP.

600.03 Notification of Judicial Order or Subpoena

In case the SC Director receives a judicial order or subpoena for records (see Notification of Judicial Order of Subpoena), the consultations and procedures outlined in the previous section should be followed.

605. CORRESPONDENCE

605.00 Correspondence: Mail Handling

Although administrative procedures and assignments in UOEAP are under continual review, staff responsibilities are organized generally along regional and functional lines. UOEAP provides staff and regional responsibility charts and an organizational chart on EAP’s Contact Information web page.

UOEAP typically sends a mailing once a week to Study Centers via overnight courier; the package usually contains correspondence from several staff members. Important or time-sensitive materials are sent individually as needed. Correspondence sent from Study Centers to UOEAP, even though directed to different persons on the staff, should be sent in one envelope to save mailing costs and to expedite distribution and review. Personal or confidential correspondence should be sent in a separate envelope marked appropriately for the intended recipient.

605.01 Electronic Mail

All Study Centers are equipped with computers and Internet and e-mail access for the SC Director and staff. During orientation, SC Directors should remind students to keep their e-mail addresses (and other contact information) updated in MyEAP throughout the program to facilitate timely communication for routine program business or in the event of an emergency. (See EAP’s E-mail Policy for Messages Containing Information on Specific Students.)

Given that so much information (both confidential and non-confidential) about students circulates within UOEAP, the Campus EAP Offices, the Study Center, campus Student Health Services, Counseling and Psychological Services, the Office of the General Counsel, etc., EAP must strenuously attempt to protect student privacy when communicating with or about students, even though both the nature of e-mail and the public character of the University’s business make e-mail less private than users may anticipate. Exercise extreme caution in using e-mail to communicate confidential or sensitive matters as UC policies indicate that e-mail, whether or not created or stored on University equipment, may constitute a University record subject to disclosure under the California Public Records Act or other laws, or as a result of litigation.

The confidentiality of e-mail cannot be assured and such confidentiality may be compromised by unintended redistribution. Therefore, all EAP staff must follow e-mail guidelines governing the use of the subject line and the addition of a Confidentiality Footer within the text of an e-mail.

The subject line should read as follows: “[Name of student]—[Country, Program Name].” For example, “John Smith—France, Lyon Year.”

For confidential matters, such as health or disciplinary actions, the name of the student should not be included in the subject line; however, it can be used in the body of the e-mail.

The subject line should read as follows: “CONFIDENTIAL—[Topic].” For example, “CONFIDENTIAL—Letter of Reprimand, Student at HKU Fall 0708,” or “CONFIDENTIAL—Psychotropic Information.”

The use of an e-mail confidentiality footer serves as a reminder that EAP values the privacy of e-mail communication. It also serves a practical purpose if there were ever a records request for these e-mails, since the confidentiality footer identifies messages as potentially containing private information. It should be noted that the existence of the footer probably would not change the legal analysis of whether any particular message contained private information—either the information is private or it is not, and the footer cannot make it private if it is not. UOEAP will include a confidentiality footer in all e-mail correspondence about a student, regardless of whether the communication is confidential. This footer should read:

This e-mail and any files transmitted with it may contain privileged and confidential information subject to privacy regulations. This information is intended solely for the use of the individual or entity to which it is addressed. If you have received this message in error, please notify us and remove it from your system.

605.02 Correspondence with Campus EAP Offices

With EAP locations in 35 countries worldwide, knowledge sharing, efficient communication protocols, and collaboration between the on site and US teams is critical for successful EAP operations. Academic and Operations Specialists in the regional teams at UOEAP serve as liaisons between Campus EAP Offices and Study Centers. This helps EAP to 1) coordinate activities and the sharing of accurate information among different constituents; 2) limit EAP’s legal exposure by providing one consistent and centralized forum for the exchange of information; and 3) provide updates of new information, policies, and procedures. Therefore, all communication among the Study Centers and the campuses that involves discussion, interpretation, or decisions regarding policy and procedures must be routed through UOEAP. Specialists at UOEAP serve as the liaison with the Study Centers to coordinate issues between the host university and Study Center and each UC campus. This communication approach still provides a timely and consistent response and enables consistent action and follow-through, as necessary and appropriate, by UOEAP staff.

Communications concerning the application of an individual student’s EAP course work to home campus departmental or college requirements or course registration for return to the home campus may be directed to the appropriate campus staff without routing through UOEAP. (See the charts for EAP campus contacts on EAP’s Contact Information web page.) It is recommended that the relevant Academic Specialist be copied on these communications as it is helpful for staff at UOEAP to know how EAP course work is applied at the campuses.

605.03 Telephone

Lists with UOEAP and campus EAP staff phone numbers and rosters with full information on contact points for all Study Centers are available on EAP’s Contact Information web page.

605.04 Communications with Parents and Other Relatives

FERPA (Family Educational Rights and Privacy Act) and the UC systemwide policy do not permit indiscriminate disclosure of student information to parents without the specific written consent of the student. The act shifts the rights and protections away from parents and toward students (regardless of the students’ ages) once students enroll in an institution of higher education. According to FERPA, EAP generally cannot share confidential information (non-directory) about a student with third parties, including parents, unless the student provides written consent or the information being shared is directory information that the student has not blocked from being released; therefore, SC Directors cannot release specific information about students unless there is a health or safety emergency.

If the student has requested a higher level of confidentiality, technically, the SC Director cannot acknowledge that the student is participating in EAP unless there is a health or safety emergency (see Section 600.00, Student Records). UOEAP and the SC Director must have written permission from the student to talk to parents or other relatives, including the disclosure of whether or not the student is a participant in the Program. Completely public information is not required to be given out except in response to a Public Records Act request, which has to be made in writing. (See the Student Information Release Matrix.) For these students, EAP may share information internally only on an official “need to know” basis, and EAP may disclose information to parents or others only if there is a health or safety emergency.

UOEAP acts as the conduit of information between relatives of students and the Study Center. UOEAP’s business practice approach is not to give out information to anyone on the phone claiming to be a parent or relative of a student. Therefore, if the SC Director receives correspondence or telephone calls from parents or other family members, the SC Director should inform the relative that he or she will investigate the matter and will call the parent or relative back. It is the student’s responsibility to keep parents informed about his or her well-being, academic record, etc. The SC Director must obtain written permission from the student to discuss the student’s personal life, financial status, academic program, progress, or records with anyone. If the student chooses not to inform the parent or relative, the SC Director may not do so unless it is a health or safety emergency. If the matter goes beyond answers to routine questions, the SC Director should send the reply to UOEAP for discussion with the relative. The SC Director should keep UOEAP informed of any ongoing discussions with a relative.

Exceptions to this policy for all students are health and safety emergencies in which the student is incapacitated (such as by a life-threatening illness or accident) and is unable to inform the parent, give informed consent for personal treatment, or give permission for the SC Director to contact his or her parents. If the student is incapacitated and the SC Director believes his or her own response is in order, the SC Director should communicate with UOEAP. UOEAP will consult first with the General Counsel’s Office in the UC Office of the President before contacting parents without the consent of the student.

605.05 Communicating during an Emergency

In the event of an emergency, such as a natural disaster or political upheaval in the Study Center country or region, the SC Director should communicate with UOEAP at the first possible opportunity regarding the safety and security of UC students. The SC Director should contact all participants to ascertain their well-being and to alert students to contact their parents, partners. relatives, or emergency contacts as soon as possible. The SC Director should be able to account for all students (even if the natural disaster takes place in a different part of the country) and notify the Regional Director at UOEAP as soon as possible. UOEAP will then inform the Campus EAP Offices and EAP students’ parents as appropriate. SC Directors should bear in mind that family and friends of program participants may not have a clear understanding of host country geography; an event such as an earthquake may cause alarm even if it takes place several hundred miles from the program site.

Additional steps to take in emergency situations are included in the Study Center Emergency Preparedness Handbook. The home phone numbers and cell phone numbers of key UOEAP staff to contact during an emergency (if it occurs outside office hours) are listed in the Study Center Emergency Preparedness Handbook and are regularly updated on the EAP Emergency Contacts web page. In addition, the SC Director must provide UOEAP with his or her home and cell phone number.

UOEAP maintains a public emergency web page to inform families about the process to follow when they are concerned about a health or safety emergency for an EAP student currently abroad. Twenty-four-hour contact information is provided for the UOEAP office. The page periodically includes communiqués on EAP’s position during major international events that affect EAP as a whole.

605.06 Safety and Incident Reporting

The SC Director must immediately complete and send to the Operations Specialist a Safety and Incident Report (available in both writeable PDF and Word formats) for any crimes or incidents reported by a student that involved bodily harm, the threat of bodily harm, or racially motivated verbal or physical harassment. Note that stalking behavior should be considered an incident that involves threat of bodily harm, even if no direct threat is verbalized.

Robbery (defined as the taking or attempting to take anything of value under confrontational circumstances from the control, custody, or care of another person by force or threat of force or violence and/or by putting the victim in fear of immediate harm) and burglary (defined as the unlawful entry into a building or other structure with the intent to commit a felony or a theft) must be reported on a Safety and Incident Report. As with any form of major crime, the report should be completed and submitted to the Operations Specialist as soon as possible after the incident occurs.

A separate Safety and Incident Report does not need to be completed for individual instances of minor street crime, including petty theft like pick-pocketing (a form of street crime that causes little objective damage but a great deal of alarm). A summary of all such known instances that happened during the year must be reported on the Annual Safety and Incident Report. However, as with any crime, students who are victims of petty theft should be encouraged to file a report with the local police.

If there is any doubt about whether a form should be filled out, the SC Director should err on the side of completing a form or contact the Operations Specialist at UOEAP. SC Directors should keep the Regional Director and Operations Specialist informed and updated about the nature and urgency of each student incident abroad. It is essential to hear first from the Study Center, before parental or media contacts start.

As an appendix to the Annual Report, the SC Director should complete a more detailed Annual Safety and Incident Report that summarizes incidents that took place over the course of the year.

605.07 Communication Guidelines: Infectious Diseases

Listed below are EAP guidelines for communicating about infectious diseases. These guidelines are based on EAP’s experience dealing with past health-related outbreaks. They will be reviewed and updated as new information becomes available.

The SC Director will need to work closely with EAP regional staff and the Principal Policy Analyst on all communications to students relating to major infectious diseases. It is crucial that the SC Director consult with UOEAP as appropriate before sending anything about these matters to students, parents, or other public venues.

605.08 Study Center Files: Retention of Material

To maintain continuity, it is necessary to keep general Study Center correspondence, Registration Study Lists, petitions, and grades at the Study Center for three years. Any material that might be of help to an incoming SC Director should also be retained. Files on students are kept at UOEAP for five years. The SC Director should forward specific information to UOEAP on particular students if the SC Director feels the information should be incorporated into the student’s UOEAP file.

610. INFORMATION TECHNOLOGY (IT) SUPPORT

610.00 Information Technology (IT) Study Center Support

For IT Study Center support information on hardware and software procurement, inventory management and licensed software downloads such as Antivirus and Office 2003, visit the IT Study Center Support web page. Check the page regularly for updates.

If you have questions or comments about this site or need technical assistance, contact the IT Support Liaison for Study Centers at scsupport@eap.ucop.edu.

615. STUDY CENTER DIRECTOR’S REPORT

615.00 Study Center Director’s Report

620. ILP REPORT

620.00 ILP Report

625. ACADEMIC PROFILES

625.00 Academic Profiles

630. EAP RECRUITMENT, ADVISING, AND ORIENTATION MATERIALS

630.00 EAP Websites

The Campus EAP Offices maintain websites that contain information specific to campus operations. They link to the UOEAP website for program information.

All SC Directors and EAP students are encouraged to send information they consider useful for prospective EAP participants to UOEAP for possible inclusion in the UOEAP website.

630.01 Recruitment and Orientation Materials

SC Directors are asked annually to provide input for EAP recruitment and orientation literature (e.g., country brochures and Student’s Guides). It is critical that the SC Director thoroughly reviews the material and responds with his or her comments and revisions by established deadlines.

SC Directors and students are encouraged to provide UOEAP’s Strategic Marketing and Communications (SM&C) unit with photographs for use in publications and the UOEAP website depicting:

On a case-by-case basis, UOEAP may authorize selected Study Centers to receive professional photography support.

In addition, UOEAP welcomes recruitment materials describing the host university and city in published and audiovisual formats. Materials that the SC Director thinks would be useful in recruitment and in sustaining an applicant’s interest should be sent to the SM&C unit in sufficient quantity for UC campus distribution.

630.02 Student Highlights/Testimonials/Articles

Student stories and comments on the value of EAP are featured throughout EAP’s website and in various publications. SC Directors are requested to identify students who have had positive experiences on the program and encourage them to e-mail their experiences to the SM&C unit (communications@eap.ucop.edu). In addition, the unit will contact students after their return to solicit stories, comments, and photos.

630.03 News Releases

EAP sends out periodic news releases that highlight new program innovations and interesting student or SC Director projects abroad via the UC NewsWire. SC Directors are asked to submit newsworthy topics to SM&C at communications@eap.ucop.edu.

630.04 Subject Areas Lists

SC Directors are asked to elaborate on academic offerings in the annual report and in the Academic Profile. (See Section 235.00, Annual Report; and Section 235.05, Academic Profiles.)

630.05 Host Institution Academic Calendar

Academic program calendars are used at UOEAP and in a number of offices on the campuses. The calendars must include beginning and ending dates for all terms, the arrival and EAP orientation dates, the ILP schedule, term breaks and vacation dates, exam periods, and important multiple-day holiday dates within the host country’s culture.

Each year SC Directors are requested to provide dates to the relevant Operations Specialist for the following year. At Study Centers where actual host institution dates are not available at the time requested, SC Directors should provide their best projections for the following year based on the current year’s academic calendar and then forward verified dates to the Operations Specialist as soon as they are known.

630.06 Logos

Study Centers may use the unofficial seal of the UC and/or EAP logos on official Study Center materials, accessible on the Logos page of EAP’s Shared Resource Library.

635. STUDY CENTER WEBSITES AND SPECIAL DIGITAL APPLICATIONS

635.00 Study Center Website Content and Guidelines

Note: All of the Study Center websites can be accessed at eap.ucop.edu/sc.

Study Center websites are created and maintained by UOEAP’s Strategic Marketing and Communications (SM&C) unit with content provided by the Study Center. UOEAP provides each Study Center minimally with a one-page website that includes Study Center location, staff, and contact information; links to the websites of the universities served by the Study Center; a Sign-Out form to identify student travel and to facilitate student security; and a link to the UOEAP website. Study Centers that wish to create and maintain their own websites must seek approval from UOEAP’s Chief Administrative Officer.

Study Center websites are intended to support the UC students who are currently enrolled and on site in a program supported by the Study Center. The Study Center website provides a range of information that students need to help ensure that their academic experience abroad is as successful as it can be.

Other web pages within the EAP website address these three support needs. If Study Centers have specific information or instructions for reciprocity or faculty exchange, this content will be posted in the appropriate locations on the EAP website.

By defining the audience narrowly for Study Center websites, UOEAP can assure a greater level of security and a more focused scope of presentation for the content of the website.

Each Study Center website utilizes the same basic design template. As a systemwide program, EAP develops support tools that reflect a consistent design approach and look. Use of the Study Center templates provides a predictable platform to ensure that EAP networks are secure and technology needs are met as effectively and efficiently as possible. This continuity of presence also means that the websites do not necessarily have to be redesigned or changed dramatically as SC Directors change.

The one-page basic website can be expanded to include additional pages and information the Study Center desires, such as general announcements, course information, program calendars, cultural information, housing and logistical information, and general announcements on upcoming field trips and events. For examples of expanded sites, see the China website and the UK California House website. (See also Section 635.01, Summary of Study Center Website Content.)

Developing expanded content requires Study Centers to commit to regular review and update of the information provided on their site so that it remains accurate and timely. Content development, text editing, and proofreading are the responsibility of the Study Center. Materials for the Study Center website can be sent via e-mail as attachments or via FTP if there are multiple or large files.

SM&C staff will upload finalized content within two workdays of its receipt. Initial development of expanded sites may take longer, depending on the complexity. If interested in expanding the website, the SC Director or designated SC staff member should send a note to scwebsite@eap.ucop.edu indicating his or her specific needs.

The EAP security policy for Study Center websites is to limit risk to students as potential targets for harm or terrorism by publicly exposing their identities while they are actively resident at Study Centers or by publicly disclosing the time and place for EAP gatherings via a website. Therefore, for safety and security reasons and to protect the privacy of EAP students, Study Center websites will not be permitted to support current student images, student lists, student contact information, e-mail addresses, or detailed meeting logistics. Instead, use e-mail for such communication needs.

Study Centers should use e-mail or hard copy distribution to communicate security sensitive information. E-mail correspondence to students provides significantly less risk than website postings for communicating information such as names of fellow EAP students, times and places of meetings, and where to gather for trips. It is also more effective because it is actively sent instead of being passively available for students to find. Note that when sending mass e-mails to a group of students, you must use the “Bcc” line. This is for security and privacy reasons because many e-mail providers spam messages with multiple addresses in the “To” line and because some students do not give consent to share their e-mail addresses with others.

Study Center websites should not be used to support advanced instructional support for individual faculty courses. Such course-specific websites would require design and maintenance resources and/or network access with administrative privileges (see Security and Integrity of Data and Networks below). Linkages may be established between instructional websites and Study Center websites, as long as network security is not compromised. Study Centers that wish to support instructional websites for individual faculty courses should identify their needs in a note to scwebsites@eap.ucop.edu so that resolutions can be developed.

For network security reasons, Study Center staff are not permitted to offer or create any web application or tool that requires them to have direct network access with specific administrative privileges to UOEAP’s network infrastructure.

635.01 Summary of Study Center Website Content

635.02 Special Digital Applications

Study Centers may receive limited support from UOEAP to create web-based applications subject to available resources at UOEAP and to capabilities of the individual Study Center. Examples of recent UOEAP-supported digital projects include a video project in France and a live journal project in Germany. For the digital video project, the SC Director interviewed students regarding their experiences and sent minimally edited video clips to be posted to the EAP website. For the live journal project, the SC Director selected students to record their experiences and correspond with prospective students, and monitored content.

EAP’s Strategic Marketing & Communications and Information Technology units will consider special requests for special web-based applications. SC Directors interested in developing a special web-based application should send a brief description of the project idea to communications@eap.ucop.edu for consideration.

640. CATALOGS/UC PUBLICATIONS

640.00 Host University Catalogs

SC Directors should provide regional staff with ten copies of the host university catalogs as they become available each year. These are used by the Campus EAP Offices in advising prospective participants and by UOEAP for host university descriptions, course approval reference, and calendar information. The importance of obtaining these catalogs cannot be overemphasized. SC Directors should send the copies to the relevant Academics Specialist at UOEAP via airmail rather than surface mail in order to avoid delay in receipt. If the host university does not publish a paperbound catalog, but rather a clothbound volume, the SC Director should send eleven copies of the clothbound books (even if they must be purchased). If a host university does not issue a catalog for the academic year, the SC Director should notify regional staff accordingly so that UOEAP and the Campus EAP Offices can be made aware that only previous catalog materials are available for reference.

640.01 UC Campus Catalogs/UC Directory

UOEAP rarely mails reference publications abroad. UC catalogs and schedule of classes can be accessed on the UOEAP website. Contact information for UC faculty and staff is accessible online in the UC Directory.